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<br />in Idaho which failure resulted in the death of at least <br />nine persons and damages estimated at one billion dollars <br />or on any geologic formation which might prove unstable. <br />Defendants' failure to investigate and report on the <br />. Narrows Dam site is contrary to the mandate in NEPA to <br />protect the human environment. The changes and increased <br />costs as proposed by defendants will make the Narrows a <br />different project than authorized by Congress and defendants <br />should be enjoined from proceeding with the project until <br />such time as seepage loss data is available to determine <br />whether defendants should be required to resubmit the <br />Narrows project to Congress for reauthorization. <br />28. Defendants have failed to adequately describe <br />the impact of aggradation problems at the inlet end of <br />Narrows. The deposit of sediments will provide an excellent <br />ecological system for the growth of phreatophytes to deplete <br />the stream of project water and to require additional <br />operational and maintenance expenses to control and remove. <br />Aggradation below or downstream of the Narrows is a serious <br />flood threat to life and property. Bijou Creek during times <br />of flood carries heavy sediment deposits which will be <br />deposited in the South Platte River changing the historical <br />flow of the river and threatening to flood new lands not <br />previously flooded by waters of tributaries flowing into the <br />South Platte River below the Narrows. The aggradation <br />problems will be increased as a result of controlled releases <br />from Narrows which will not scour out deposits from the <br />tributaries. These impacts are not adequately accounted for <br />in FES. <br />29. Defendants have failed as of this date to make <br />public documents available to plaintiff, RLG, or its agents <br />in contravention of the Freedom of Information Act, 5 u.s.c. <br />Sec. 552. <br /> <br />-13- <br />